AMCs Violating TILA and C&R Fee Clauses
Fellow Appraisers, the appraisal industry has been facing a major issue with AMCs violating the Truth in Lending Act (TILA) and the Customary and Reasonable fee clauses. This has not only caused harm to consumers but also to appraisers who are struggling to make a living. Despite efforts to bring this issue to light, it has been largely hidden from the public and regulators. However, it is time to change that and reveal the truth about what is really happening. To do so, we need to gather more data and evidence to establish a pattern of violations for these bids and “proposals“. This is why an excel sheet has been created for individuals to fill out with specific information such as dates, addresses, lenders, AMCs, and fees.
For the past year, there have been ongoing efforts to address the issue of AMCs violating TILA and the Customary and Reasonable fee clauses. While a significant amount of information has been gathered, it is not enough to truly showcase the extent of the problem. This is why it is crucial for appraisers to come forward and provide their own experiences and data. We understand the fear of retaliation and being blacklisted by AMCs, but rest assured that the information provided will not be shared publicly. It has a specific purpose of bringing to light the truth about what is happening and taking back control of our profession. Many of you will know the individuals who have been working on this, while some of you will just be finding out about this. If we want to see real change and put an end to these violations, we need to show it with significant data and evidence.
The damage caused by AMCs violating TILA and the Customary and Reasonable fee clauses goes beyond just financial losses. It affects the credibility and integrity of the appraisal industry as a whole. Consumers are being misled and overcharged, while appraisers are being underpaid and undervalued. This not only harms the individuals involved, but also has a negative impact on the housing market and the economy. By gathering and presenting concrete data, we can show the true extent of the damage and demand for change. It is time to take a stand and fight for fair and ethical practices in the appraisal industry. Let us come together and show the truth of what is happening, for the sake of both consumers and appraisers alike.